Black Country Core Strategy Issue and Option Report

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Black Country Core Strategy Issue and Option Report

Question 57 - Do you support the proposal to merge Policy CEN1 and Policy CEN2, given that both policies focus on the overall strategy in the Black Country, including the hierarchy of centres? Yes/No

Representation ID: 1062

Received: 08/09/2017

Respondent: Aldi Stores Ltd C/o Turley

Agent: Turley Assocs

Representation Summary:

We would have no in principle concern with Policy CEN1 and CEN2 being merged. Our client is more concerned with the content of the policy as a whole.

Attachments:

Object

Black Country Core Strategy Issue and Option Report

Question 58 - Do you think there is any evidence to suggest that the hierarchy of centres is not appropriate going forward in the context of the regeneration strategy? Yes/No; If so, please provide de

Representation ID: 1066

Received: 08/09/2017

Respondent: Aldi Stores Ltd C/o Turley

Agent: Turley Assocs

Representation Summary:

The hierarchy of centres currently set out in the Core Strategy is appropriate in principle, e.g. the identification of strategic, town and local/district centres. The existing Core Strategy is, however, too prescriptive as to the level of development which can be brought forward in, or on the edge of, any of the particular centres. This policy, which only supports proposals considered proportionate in scale to the centre they are in, was based on the national policy at the time (which predated the NPPF).

The concept of trying to dictate at plan level the scale of development appropriate within individual centres in order to safeguard a given centre hierarchy, is no longer supported by national guidance. National policy now requires Local Authorities to plan positively, to support development within town centres and to promote competitive town centres, without specific reference to the potential effects of development in 'Centre A' or 'Centre B'.

Attachments:

Comment

Black Country Core Strategy Issue and Option Report

Question 59 - Have all the appropriate centres within the Black Country been identified? Yes/No; If not, please specify additional centres.

Representation ID: 1070

Received: 08/09/2017

Respondent: Aldi Stores Ltd C/o Turley

Agent: Turley Assocs

Representation Summary:

The centres included in the hierarchy should be objectively reviewed as part of the Core Strategy Review. The retail evidence base, which should underpin the relevant policies, must clearly identify a consistent set of parameters for assessing the status of individual centres. This should be applied across the four Local Authorities in an objective way.

Attachments:

Support

Black Country Core Strategy Issue and Option Report

Question 60 - Is there evidence to suggest that identified centres are no longer performing as a centre or at their identified level in the hierarchy? Yes/No; If Yes, do you agree that they should be

Representation ID: 1073

Received: 08/09/2017

Respondent: Aldi Stores Ltd C/o Turley

Agent: Turley Assocs

Representation Summary:

This should be revisited to take account of the updated retail evidence base.

Attachments:

Comment

Black Country Core Strategy Issue and Option Report

Question 61 - In addition to para 4.33 of the current Core Strategy should the revised Core Strategy include criteria for the creation of new centres that might be needed as a result of any additional

Representation ID: 1083

Received: 08/09/2017

Respondent: Aldi Stores Ltd C/o Turley

Agent: Turley Assocs

Representation Summary:

It is difficult to set out specific criteria in the Core Strategy to guide any potential new centres. The Core Strategy should, however, recognise that new strategic housing developments/urban extensions may require well located new centres to serve them.

Attachments:

Object

Black Country Core Strategy Issue and Option Report

Question 64 - Is there a need to set targets for convenience retail floorspace in the Core Strategy? Yes/No; Any further comments?

Representation ID: 1087

Received: 08/09/2017

Respondent: Aldi Stores Ltd C/o Turley

Agent: Turley Assocs

Representation Summary:

No, there is no need to set targets for convenience retail floorspace.

The retail evidence base assesses capacity for new retail floorspace based on population and expenditure projections. This information should be reviewed regularly in light of the particularly dynamic nature of the retail sector. Such assessment of 'need' should never be considered as targets, the likely consequence of which would be to introduce 'need' into development management decisions, contrary to national policy.

Attachments:

Support

Black Country Core Strategy Issue and Option Report

Question 74 - In the context of the 'centres first' strategy, should the threshold approach be reviewed to consider the appropriateness, scale and impact of development in and on the edge of Strategic

Representation ID: 1096

Received: 08/09/2017

Respondent: Aldi Stores Ltd C/o Turley

Agent: Turley Assocs

Representation Summary:

The approach taken to the application of thresholds in defined centres in the current Core Strategy is overly complicated and confusing. It is too prescriptive and is predicated on outdated national planning policy, which was concerned with directing development of particular scales to 'appropriate' centres within the defined hierarchy. This approach is no longer supported by national policy.

As currently worded, even schemes of a relatively modest scale within (and on the edge of) certain designated centres would exceed the local threshold for an impact test. Given that the Core Strategy is based on meeting the need for town centre uses in accordance with the sequential approach, issues of adverse impact should not arise. It is also important that planning policies are positive and promote competitive town centre environments.

The various thresholds set out for different types of centres should be deleted, instead relying on those set out in national guidance (applying to schemes over 2,500 sq m). It is for individual Local Authorities, when preparing their own Local Plans, to justify departures from that threshold.

Attachments:

Object

Black Country Core Strategy Issue and Option Report

Question 76 - Is the approach set out in Policy CEN6 appropriate in the context of supporting local community needs? Yes/No; Please explain why.

Representation ID: 1097

Received: 08/09/2017

Respondent: Aldi Stores Ltd C/o Turley

Agent: Turley Assocs

Representation Summary:

The threshold approach and reference to 200 sq m is arbitrary and unjustified. In general terms, there is no justification for adding an extra layer of protection to locations which are not identified as designated centres through the Core Strategy. The policy should reflect the NPPF and the definition of town centres set out in Annex 2.

Attachments:

Object

Black Country Core Strategy Issue and Option Report

Question 81 - Do you agree that the approach of strong control over out-of-centre development is still appropriate in the context of the strategy to ensure the vitality and viability of the Black Coun

Representation ID: 1100

Received: 08/09/2017

Respondent: Aldi Stores Ltd C/o Turley

Agent: Turley Assocs

Representation Summary:

The Core Strategy currently takes the approach that out of centre development is an inherently undesirable form of development. In the context of the NPPF there is a need to take a positive approach to sustainable development in plan making and decision taking. There are now only two development management tests for retail development - the sequential assessment and impact. Subject to meeting the necessary tests, there is no reason why out of centre development should not be welcomed.

Given the significant requirement for new housing across the Black Country, there is a requirement for a less rigid approach to be taken to meeting the need for future retail provision. Whilst there is general support for a town centre first policy, it is important to ensure that at the local plan level identified needs can be accommodated and delivered within or adjoining designated centres. Currently there is a tendency for town centre boundaries to be tightly drawn and reluctance by Local Planning Authorities to extend centres to allow new retail development.

Attachments:

Object

Black Country Core Strategy Issue and Option Report

Question 82 - Is 200sqm (gross) an appropriate scale of development above which the impact tests should apply? Yes/No; Please explain why.

Representation ID: 1102

Received: 08/09/2017

Respondent: Aldi Stores Ltd C/o Turley

Agent: Turley Assocs

Representation Summary:

The 200 sq m threshold is not appropriate and is far too low. The threshold is arbitrary and is not based on empirical evidence.

As it stands, the application of a 200 sq m threshold would be triggered by virtually all convenience retail schemes. We also object to the application of the threshold to what would be very modest extensions to
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existing stores, even if the extension was ultimately to provide a small increase to circulation or welfare space, rather than actually increase the retail/sales floorspace per se.

We would recommend that a strategic level document such as the Core Strategy defaults to national policy in terms of thresholds for applying the impact test. If individual Local Authorities can justify lower thresholds through a robust evidence base, the relevant local plan is the appropriate vehicle for setting such thresholds.

Attachments:

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